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11 January 2001 Internal T.I. 2000-0001017- Sourcing of income & foreign tax credit-- summary under Subparagraph 115(1)(a)(ii) Summary Under Tax Topics- Income Tax Act- Section 115- Subsection 115(1)- Paragraph 115(1)(a)- Subparagraph 115(1)(a)(ii) place of contract not primary determinant The Directorate agreed that the taxpayer, which was a Canadian manufacturer transferring some of its goods to a Japanese branch for sale there, was overstating its profits for purposes of s. 126(2), by treating most or all of the profits on the sale of such products as being profits of the Japanese branch. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Subsection 126(1) Summary Under Tax Topics- Income Tax Act- Section 126- Subsection 126(1) no pro-ration of FTC by s. 94 trust where Canadian gain was smaller than US gain A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...

28 May 2013 Internal T.I. 2013-0476381I7- Deemed Resident Trusts & Foreign Tax Credit-- summary under Paragraph 94(3)(b) Summary Under Tax Topics- Income Tax Act- Section 94- Subsection 94(3)- Paragraph 94(3)(b) A trust was settled in the U.S. with marketable securities having an adjusted cost base and fair market value of $100,000. ...

30 September 2013 Internal T.I. 2012-0439661I7- Income earmarked for future use & 95(2)(a)(i)-- summary under Subparagraph 95(2)(a)(i) Summary Under Tax Topics- Income Tax Act- Section 95- Subsection 95(2)- Paragraph 95(2)(a)- Subparagraph 95(2)(a)(i) funds earmarked for future projects of sister affiliates A CFA of Canco held funds generated from projects which were owned and operated by FA1, with the funds being "earmarked" for future investment in projects to be carried out by other CFAs of Canco. ...

16 November 2015 Internal T.I. 2015-0598491I7- 91(5) & FAPI included per “old” 94(1)(c)(i)(C)-- summary under Subsection 91(5) Summary Under Tax Topics- Income Tax Act- Section 91- Subsection 91(5) upward ACB adjustment to the CFA occurring as a result of recognized FAPI under the old s. 94(1) rules represented basis that could be distributed while the trust was subject to the new s. 94(3) trust rules A non-resident discretionary trust (“NRT”) owned all the shares of CFA. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Paragraph 8(b) Summary Under Tax Topics- Income Tax Regulations- Schedules- Schedule II- Class 8- Paragraph 8(b) property does not satisfy the “solely” test in Class 8(b) where it was necessary for the proper functioning of the building The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ...

18 May 2022 Internal T.I. 2018-0788761I7 F- Amortissement – Travaux sur un bien loué et F&T-- summary under Subsection 1102(5) Summary Under Tax Topics- Income Tax Regulations- Regulation 1102- Subsection 1102(5) building shell was a building or structure/ addition refers to extension of structure The taxpayer, which subleased premises containing “Shells” consisting essentially of foundations, walls and roofs, installed wall and floor coverings and performed electrical, ventilation and plumbing work to make the premises suitable for use in its manufacturing and processing (“M&P”) operations. ...

1 February 2018 Internal T.I. 2016-0671921I7- R&D Services- 95(2)(b) vs 247(2) & 95(3)(b), (d)-- summary under Paragraph 5907(1.3)(a) Summary Under Tax Topics- Income Tax Regulations- Regulation 5907- Subsection 5907(1.3)- Paragraph 5907(1.3)(a) overview of FAT rules re consolidated US return with R&D credit Four U.S. ...

The mid-amble of subsection 13(29) … clearly indicates that the taxpayer must file a single election with its return for the “particular year” …. Once the Long-Term Project election has been filed with its return for the particular year, subsection 13(29) will apply in respect of the taxpayer’s “inclusion year” … [which g]enerally … will be the third and subsequent taxation years of the project where the taxpayer owns project property in that taxation year that has not yet otherwise become available for use. … … The … current … Form T1031 suggests that the form must be filed annually. … Form T1031 is currently under review. ...

The Directorate responded: [S]ubsection 246(1) is generally a provision of subsidiary application since it must be shown that the value of the benefit is not otherwise included (for example, by virtue of paragraph 6(1)(a) or subsection 15(1)) in computing the taxpayer's income …. On the other hand … Massicotte … held that the Minister of National Revenue may assess a taxpayer solely on the basis of section 246 despite the fact that paragraph 6(1)(a) could have been argued …. … Thus, while the Minister may invoke subsection 246(1) as the sole ground for assessment, we believe it is preferable that the assessment refer- if the facts of the situation are appropriate- to the provisions of specific application. … [T]herefore … the assessment should rely on paragraph 6(1)(a) and/or subsection 15(1) as the main grounds …. ...